ML20072J108
| ML20072J108 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/27/1982 |
| From: | Robert Davis BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-04, TASK-11, TASK-4, TASK-GB NUDOCS 8306290931 | |
| Download: ML20072J108 (61) | |
Text
bt UNITED STATEhiDISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
_ _x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, 4
METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against-80 Civ. 1683 8
(R.O.)
THE BAECOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INO..
l De*endanta.
i
__.. _____ _ _ _ _x
=
Deposition of RONALD DAVIS, taken by Plai ntif fs, pursuant to Notice, t$ ' the offices of Kaye, Scholer, Fierman, Hays & Handler, Esqs., 425 Park Avenue, New York, New York, e
on Tuesday, April 27, 1982, at 9:45 o' clock in the forenoon, before Catherine Cook, a
(
Shorthand Reporter and Notary Public within and for the State of New York.
8306290931 820427 PDR ADOCK 05000289 T
PDR DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS 369 LExlNGTON AVENUE WALTER SHAPIRO, C.S.R.
NEw YomK. N.Y.
10017 CHARLES SHAPIRO, C.S.R.
TELEPHONE 212 - 867-8220 1
i l'
2
.,m; 2
Appe a ran ce s:
s 3
4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs
' {,
5 425 Park Avenue New York, New York 6
Bp:
RICHARD C.
SELTZER, ESQ.,
7 of Counsel 8
~
9.I l
DAVIS FOLK & WARDWZL?U, ESQ5.
t 10 g
l Attorneys for Dalendants 11 l
One chass Manhattan Plaza New York, New York 12 1
(_h t
By RODMAN W.
BENEDICT, ECQ.,
/
13 of Counsel 14 15 e
y 16 17 18 IT IS HEREBY STIPULATED AND AGREED by and 10 between the attorneys for the respective 20 Parties hereto that the sealing, filing and l
21 certification of the within deposition be, 22 and the same hereby are, waived; that the 23 transcript may be sign'ed before any Notary
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l
(
24 Public with the same force and effect as if N.
25 signed before the Court.
l I
m e
1-3
/~N 5
i 2
IT IS FURTHER STIPULATED AND AGREED that 3
all objections, except as to the form of the 4
question, are reserved to the time of trial.
l 5
(
6 7
0 RONALD DA VI S,
having been firEt 9
duly sworn by the Notary Public, was exuained 1
10 and testified ac follows:
g 11 (Resume of Ronald DaviJ marked GPU I2 Exhibit Nc. 506 for identificati:n as of I
(
13 this date.)
14 EXAMINATION BY MR. SELTZER:
15 g
We have just marked for identification as 16 GPU Exhibit 506 a resume of Ronald B.
Davis.
I 17 Can you identify this, please?,
18 A
Yes, this is my resume.
i 19 Q
Who prepared it?
~
20 A
I did.
i l
21 Q
When?
(_>
22 A
Mostly last night, some before last night.
23 Q
Is it scrupulously accurate?
l A
24 A
Yes.
i 4
\\_./
25 g
What led you to pursue a Master's Degree
_7 1
Davis 4
"N
\\ /'
2 at the University of Cincinnati?
3 A
I worked with the General' Electric Company 4
in Cincinnati and they required that we either 5
take a Master's program they offered in-house or go 6
to the University of Cincinnati to take a Master's 7
Degree in Engineering, so I chosd the latter.
8 Q
What if any particular area of study 9 I were you pursuing in the 11 aster's program?
li ll 10 A
That Master's Degree was in the cerospace f
11 l
department, huc it was principally mechanically l
l l'!
criented courses, structures, vibrations.
D(,)
13 Q
When is the first point in your college 14 or graduate education where you studied thermodynamics?
15 A
I studied thermo in my BS Degree at the 16 University of Virginia.
17 Q
Did you also study thermohyraulics?
I 18 A
Yes.
19 Q
Where?
20 A
That was at the University of Virginia.
21 Q
Is thermohydraulics a part of thermo?
C.
l l
22 A
I don't understand the question.
23 Q
Is one subsumed in the other, is one a r~
24 subcategory of the other?
(T) r l
25 MR. BENEDICT:
Is thermohydraulics a
F 1
Davis 5
f~h O.
2 subcategory of thermodynamics'?
Is that the s
3 question?
4 MR. SELTZER:
Yes.
(;
5 A
Yes, I would think so.
6 Q
What aspect of.thermohydraulics did you 7
study?
8 A
lt was a general course.
It was in the 9
}
aerospace cepartment.
It didn't address any 10 particular aspects that I recall ;ther "than it wcs a 11 I general BS level course, l
12 Q
What brought an aerospace engineer from D)
.c k-13 GE to B&W7 14 A
My wife's desire to return to the state 15 of Virginia.
16 Q
There were no airplane manufacturers in 17
_ Virginia?
18 A
Yes, there were.
19 Q
Did you consider working for any of them?
20 A
No, I did not.
21 Q
What indGced you to apply at B&W7 22 A
The nuclear industry in 1973 was a booming 23 industry.
There was a lot to offer.
And the job I
[)
24 interviewed for was for a challenging job, so I 25 accepted it.
1 Davis 6
/~%
\\~s).
2 Q
When you left B&W in 1980, did you think 3
the bloom had left the rose?
4 MR. BENEDICT:
If you understand what
(
5 Mr. Seltzer means, you may answer.
You don't 6
have to use his terms.
7 A
I am not sure I understand the 8
question.
9 Q
You scid that when you went to B&W you j
thought the nuclear field had a lot of oremise.
10 l
11 When you left, did you think it had less I
12 promise in the future?
(~)
\\/
13 A
For my own personal circumstances; yes.
14 Q
Why is thct?
15 A
I had acquired an MBA with an interest v
16 in marketing architectural engineering and planning 17 services and consequently went to work for Wiley &
18 Wilson to do the same.
10 Q
Do the same what?
20 A
To market architectural engineering and 21 planning services.
22 Q
In what field does Wiley & Wilson act 23 as an AE?
[V 24 A
They are a general architectural 25 engineering and planning firm, multidisciplinary in
1 Davis 7
[j).
)
N 2
that they do mechanical, electrical, civil, 1
3 architectural engineering projects.
4 Q
Have they ever done power plants?
(-
5 A
They have done coal-fired boiler plants.
6 Q
Are they doing any currently?
7 A
They are doing architectural engineering 8
work on coal plants currently.
i 9 l Q
Are you doing any work or. electric I
19 power plants for Wiley & Wilsen?
u j
11 A
I am a business Cevelopment manager and l
li,
y prepare proposals and try to sclicit werx frcn N
i
(~)
A- -
13 electric utilities.
14 Q
I don't want to dwell on this so let 15 me try to shortcut it.
16 Do you watch for utilities that have 17 announced plans to conduct new capacity an,d then try 18 to go and visit them and interest thengin your i
19 employer's services?
20 A
Yes.
21 Q
Is that principally how you identify
(
22
' prospective utility clients?
23 l
MR. BENEDICT:
I am going to object.
f~)
24 I hope this is a short line of questioning.
x,/
25 This is beyond the relevance in this case, but
-1 Davis 8
s-2 we can go on if you are going to end up with 3
it quickly.
t 4
You may answer the question, Mr. Davis.
{
5 A
Would you repeat the question?
6 Q
Is what I described the principal way 4
7 that you as a manager for business development 8
identify prospective utility customers for Wiley &
9 Wilson?
10 A
And you preface that by say,,ing did we 11 wait for them to advartise?
l 12 Y Q
nc,
,. [('%
l k-13 Eo you wait for the utility to announce 14 that they are planning an addition to capacity before 15 you go out and solicit their business?
16 A
Principally that's the case, but sometimes 17 we also go out and make unsolicited proposals to do 18 work for the utilities.
19 Q
From 1973 through March 1979, were you, 20 in the control and performance analysis unit at B&W?
21 A
That is correct.
(
22 Q
You rose to be the head of that unit, 23 right?
I
[)
24 A
The manager of that unit, correct.
%s 25 Q
How many people reported to you as manager y
1 Davis 9
/~h s
- \\ >>-
2 of that unit?
3 A
The number varied, but ap' proximately the 4
number was 15 engineers.
5 Q
What were the principal responsibilities 6
of the control and performance analysis unit during 7
the period that you were manager?
l 8
A The principal responsibilities included 9
design and evaluation of the integrated control 10 t system.
It included a vessel model flopt testing l
11 and other hydraulics research works and it included 22 evaluation of operational transients,
/'y j
13 l
Q What else were the responsihilities of
\\
14 the control and performance analysis unit while 15 you were its manager?
16 A
Those are the only three basic 17 responsibilities that I can recall.
18 Q
What is an operational transie'nt?
19 A
Those are transients that are not 20 accident-type transients or emergency core cooling-21 type transients.
22 Q
Would an unscheduled trip of the turbine 23 be an operational transient?
/
24 Let me withdraw that.
(
25 In the terminology that you have used fo r
1 Davis 10
)
.(d-2 operational transient, was an unanticipated turbine trip an operational transient?
3 4
A I don't really recall.
5 Q
Were there any secondary side upsets that 6
we re operational transients?
7' A
Again, I can't really recall in detail g
what was and was not an operational type transient.
l I can give you a ve ry simple examplu of 9
!l 19 what I an referring to.
(
11 Case in point, when you ramp the reactor 12 from 75 percent power to 85 percent power.
I would D)\\.
- 3 tnalyze those typss of transients, whera temperatures,
(
i g4 pressures and flows would go in a reactor: coolant system.
15 Q
In all the years that you were in control I
16 and performance analysis, did your unit hdve anything 17 to do whatsoever with secondary side conditions?
18 A
Yes.
19 Q
Did you ever study secondary side upsets i
I 20 or transients?
21 A
I don't recall a specific instance.
(
j 23 Q
I didn't ask you if you can recall a 23 specific instance.
24 All I am asking you now is do you recall l
l 25 that your unit, which you served in from '73 through L
1 1
Davis 11 v
2 early
'79, ever dealt with secondary side transients?
3 A
I just don't recall.
4 Q
You honestly don't remember whether your
({ '
5 unit ever dealt with secondary side transients?
6 MR. BENEDICT:
That's what he said.
7 Asked and answered.
8 You may answer it again.
9 A
I dcn't recall.
10 Q
What socordary side conditions did you li deal with?
12 A
We dealt with the steam generator, secondary v) 13 side.
14 Q
What else?
15 MR. BENEDICT:
If anything.
16 A
Steam generator level on the secondary a
17 side was important.
Ste am gene rator pre ss,ure and 18 steam generator temperature on the secondary side 19 was important to our operational transient ~ analysis.
20 Q
What if anything else on the secondary 21 side did you study as part of any of the work of
<(
22 control and performance, not necessarily the evaluation 23 of operational transients.
. f"))
24 A
As I recall, we had models and had somewhat y
25 of secondary side modeled in order that we could do
1 Davis 12
.s
)
~J-2 the analysis on the primary system which was of concern s
3 to us.
4 But I really don't remember all the
{(
5 details of systems and components that were modeled.
6 It's been quite a few years.
7 Q
You keep repeating that as though 8
that's a phrase that you are trying to get into the 3
reco:d.
I'm not asking --
10 MR. BENEDICT:
What phrase hre we talking 11 about that he keeps repeating?
J 12-MR. SELTZER:
Please don't interrupt.
(~)
'"/
13 I am net finished, 14 Q
You keep saying that you cannot recall 15 all the details.
I am not asking for all the details.
16 I am asking you for whatever you can l
17 recollect.
If you can recall general features, I 18 want you to testify to that.
19 If I ask you for specific deta 1s, then 20 you should appropriately tell me if you cannot 21 recall specific details.
22 MR. BENEDICT:
Mr. Seltzer, I will object 23 to that statement as unnecessary.
Mr. Davis
)
~24 can testify as he understanda what the question 25 l
calls for.
.1 Davis 13
('%
2-If you want to follow up on a question, that's fine.
All Mr. Davis can do is testify 3
4 to his recollection.
(
5 MR. SELTZER:
I thought that's what I 6
just said, 7
MR. BENEDICT:
You are making a point i
8 where he said "dotails" when you didn't ask i
9 for details.
10 He can only answer the way e understands 11 the questions.
If he misunderstood it, just 12 as a follow-up question.
You don't have to fs
(
}
\\_/
13 make a lot of speeches.
14 MR. SELTZER:
I think you are the 15 speechaaker.
e 16 MR.-BENEDICT:
I think we could have 17 a competition on that.
18 MR. SELTZER:
I decline to do so.
I am t'stimony.
19 much more interested in Mr. Davis' e
20 MR. BENEDICT:
Then ask a question.
21 BY MR. SELTZER:
22 Q
You say your group had responsibility 23 for design and evaluation of the integrated control
(")N 24 system, right?
K 25 A
Yes.
4
--,e
i 1
Davis 14 s
('h
~
2 Q
Did the ICS receive inputs from any s
3 secondary side equipment?
4 A
I can't recall.
(
5 Q
What did the ICS receive inputs from?
6 A
Mr. Seltzer, I don't recall.
7 Let me make this statement so that you 8
understand that I am trying to be cooperative.
9 MR. BENEDICT:
If you want to answer the 10 question further, but I don't thin,k Mr. Seltzer 11 is suggesting you are not being cooperative.
12 You can only testify to what you can recall.
[d
\\
13 Q
Don't mind him.
14 A
I don't recall.
\\
15 I am not a controls expert.
I had 16 responsibility and reviewed to be sure that the l
j 17 integrated control system met performance. requirements 18 and design requirements, but I was not a control 19 expert and I would not really be able to recall the l
20 design philosophy and the details of the integrated l
21 control system.
l
(_ t 22 Q
I am not asking you what the design 23 l
philosophy of the integrated control system was.
24 I am not asking you about the details of the integrated i
25 control system.
s
~%
k
1 Davis 15 2
I am asking you, can you state at all from 3
all your years as manager of the unit and as an 4
Indian in the unit anything from which the ICS re'ceived 5
inputs?
6 A
No, sir, I cannot recall.
7 Q
Do you know anything to which the ICS 8
gave output signals?
9 A
The integrated control system did give 10 signals for positioning of the control ods in the 11 core in order to maintain desired power levels.
12 Q
What else?
(Qj 13 A
I can't recall.
It would be speculation.
14 I don't car'e to speculate.
15 Q
You don' t have any recollection of 16 anything else being controled by the ICS $ther 17 than the control rod position?
18 MR. BENEDICT:
Asked and answered.
19 You may answer.
20 Q
That is correct.
That's all I can 21 recall.
22-Q While you were in the control and performance 23 analysis unit, did the unit do any work that you were
's 24 aware of that related to secondary side water J
25 purification systems?
1 Davis 16 p
2 A
No, sir, I don't recall that.
3 Q
Did it do any work with respect to'the 4
condensate polisher' system?
5 A
No, sir.
~
6 Q
During the years before you became unit 7
manager, what were your areas of responsibility?
8 A
My primary responsibility the first few 9
years in the unit was to do vessel model flow test 10 work which is one-sixth scale models of the reactor g
11 vessel and internals at room temperature and pressure 12 to experimentally determine flow profiles and velocity 13 p ro file s and system pressure drops, basically 14 research and development in the hydraulic's area.
15 Q
Go on.
16 MR. BENEDICT:
After that -- br. Seltzer 17 is focusing prior to the entire time of you becoming 18 a unit manager.
i 19 A
That effort I just described is'the 20 responsibility that I had as an enginee r.
I was 21 also a supervisory engineer and had approximately seven 22 or eight of the engineers reporting to me in a 23 supervisory fashion.
_p 24 In that position, again, I was responsible Q
25 for research and development in reactor vessel
l l
1 Davis 17 2
hydraulics and analysis of operational transients.
3 Q
Did you have any other areas of 4
responsibility or specific tasks that were assigned 5
to you in the years before you became unit manager?
(
6 A
I can't recall any.
7 Q
During those years, did you serve on 8
any task force or committee or special study group?
9 A
I can't recall any.
10 Q
Did you have any special projects?
11 A
Could you explain what you mean by 12
",special projects"?
I am not sure I understand the o
\\_-)
13 term "special projects."
14 Q
Other than your day-to-day supervision 15 of the work of others on ongoing unit work or your 16 work on vessel model flow testing, did you embark 17 on any specific project?
18 A
No.
19 Q
You caid you worked with a one-51xth 20 scale model, correct?
21 A
Correct, right.
22 Q
Did that nodel have reactor coolant pumps?
23 A
No.
~ /N 24 Q
Did it have hot and cold leg loops?
'(_ )
25 A
No.
1 Davis 18 2
Q It was just a pressure vessel?
3 A
Ye8-4 Q
Your responsibility was to analyze flow
((
5 patte rns within the reactor vessel?
6 A
That is correct.
7 Q
So you would look at how baffles 8
affected flow, for_ example?
9 A
Exactly.
i 10 Q
Are there any jet pumps in a B&W vessel 11 internal?
12 A
No.
'T 13 Q
Did you ever analyze two-phase flow?
14 MR. BENEDICT:
Are we talking with 15 respect to just these models?
16 MR. SELTZER:
I will ask that first.
17 MR. BENEDICT:
I am trying to, understand 18 you are talking about now --
l t
19 MR. SELTZER:
That's all we have 20 been talking about.
21 MR. BENEDICT:
Do you understand the k_
4 22 question?
23 A
As far as vessel model flow tests, there 24 was no two-phase flow, as I stated earlier.
It 25 was a model at room temperature and room pressure and
I Davis 19
/^n s
(_).
2 we took information at those conditions and 3
extrapolated them for normal conditions for the 4
reactor.
5 Q
Did you ever do any testing in other 6
than a solid water system?
_7 A
No, sir.
It was all solid water room 8
temperature, room pressure vessel model testing.
9 Q
Your unit was part of the plant design 10 section, right?
g 11 A
Yes.
12 Q
Allen Womack was your boss from August 13
'73 until March
'79, right?
14 A
Allen Womack was my unit manager.
I am 15 not sure of the dates.
16 Q
I thought you were the unit manager.
17 A
Excuse me, he was the section manager that 18 I reported to, but I don't know about thos~e exact 19 dates.
20 Q
Was Don Roy your section manager before 21 Allen Womack?
22 A
That is right.
23 Q
A;m I correct that under both Roy and rg 24 Womack there were meetings convened approximately b
25 monthly of unit managers in the plant design section?
1 Davis 20
(\\
~
2 A
I can't recall that there were routinely 3
monthly meetings.
4 Q
Is it correct that approximately once 5
a month meetings were convened among the managers 6
of the plant design section under both Womack and Roy?
7 A
Mr. Seltzer, I really don't remember 8
any routine monthly meetings specifically for unit 9
managers.
10 Q
Under Don Roy, were there meetings 11
+ convened for managers in the plant design section?
12 A
Yes.
[h
\\,_)
'13 Q
You attended them?
14 A
Yes.
15 Q
Under Allen Womack, there were also 16 meetings convened for managers of plant design 17 section?
18 A
Yes.
~
19 Q
You attended them?
20 A
Yes.
21 Q
Did both Roy and Womack use those meetings 22 as an opport unity to dis cus s work that was going on in the 23 design section?
(~N 24 A
Yes.
tss) 25 Q
Was there oppo rtunity at those meetings
~
b s
1 Davis 21
-A 2
for unit managers to speak?
3 A
Yes.
4 Q
Did they speak?
5 A
Yes.
6 Q
If a unit manager had something of 7
significance which he wanted to bring to the attention 8
of other unit managers, could he do so at the plant 9
design section meetings?
10 MR. BENEDICT:
You are asking him what M
11 his recollection was of the practice at that 12 time?
('
13 MR. SELTZER:
Yes.
14 Q
Did that happen?
i 15 A
As I recall, yes.
e 16 Q
During the time you were unit manager, 17 Bert Dunn was also a unit manager in the p,lant 18 design section, is that correct?
19 A
That is correct.
~
20 Q
Did your unit have any dealings with i
l 21 Dunn's ECCS analysis unit?
m 22 A
Yes.
l 23 Q
In what respect?
/~T 24 A
My unit was basically responsible for N]
'25 providing initial. condition-type data for use in l
i-
N 1
Davis' 22
(A
^
2 Bert Dunn's computer models.
8 3
Q What do you mean by " initial condition"?
4 A
Things like pressures and temperatures
()
5 and flows in the reactor coolant system at particular 6
conditions but normal and partial power and other 7
operating conditions which are the initial point 8
for his computer model analysis.
9 Q
Was there any other dealing between 10 your unit and Dunn's unit?
E 11 A
None that I can recall.
12 Q
During the time you were a unit manager, f'%
\\-
13 did you speak from time to time with Bert Dunn?
14 A
Yes.
15 Q
How close were your offices to one another?
16 A
We were on the same floor; we sat against the I
17 same wall.
And there were two offices and a hallway 18 between his office and mine.
l 10 Q
Approximately how many yards sep'arated 20 your door from his?
21 A
No more than 20 yards.
22 Q
Based on your dealings with Dunn, he is 23 someone who is expertise in ECCS analysis you j
(~}
24 respected?
s-25 A
I. respected Bert Dunn's capabilities, yes.
i i
^
4
,A 1
Davis 23 2
Q Would it be fair to say that it was 3
your understanding when you were unit manager that 4
Sert Dunn was one of B&W'.s leading experts in the
(( -
5 area of ECCS analysis?
6 A
I don't know exactly what an expert is.
7 Q
Most knowledgeable is what I meant.
W 8
A He was very knowledgeable about emergency 9
core cooling.
10 I don't know that he was th'e mos t 11 knowledgeable about emergency core cooling.
12 Q
Is there anyone who you could possibly
(
\\-
13 identify'who was more knowledgeable than Bert Dunn 14 for the '77-79 period in the area of ECCS analysis?
15 A
No, I couldn't identify anyone like that.
16 Q
Did anyone in ECCS analysis ever ask 17 your unit for assistance on any particular study or 18 analysis that they were doing?
19 A
Only as I described before in that they 20 would ask for initial conditions at various normal and 21 power operating condition as input for initial 22 conditions to their ECCS models.
23 Q
Are you represented by counsel today?
24 A
Yes.
25 g
who is your counsel?
i 1-Davis 24 f]3 '
2 A
Ron Benedict is my counsel.
s' 3
Q Who is paying for your travel to New York 4
and your stay in New York?
(
5 MR. BENEDICT:
You may answer that.
6 A
Rod's firm is paying for my travel and 7
living expenses while I am in New York.
8
.Q Are you receiving any other compensation 9
in connection with your testifying here today?
10 A
No, sir.
t H
11 Q
Other than Mr. Benedict, did you meet 12 with any other counsel to prepare for your deposition?
/~
(_)T 13 MR. BENEDICT:
I object.
I am going to 14 instruct the witness not to answer.
15 I don't remember you permitting questions 16 like this when I had Mr. Mehler.
Mr. Glassman I
l 17 wouldn't let me discuss with him his, arrangement's 18 with counsel beyond the fact that he was 19 represented by both Mr. Glassman and'by criminal 20 counsel.
21 Do you mean a different firm or do you mean 22 other people within Davis Polk?
23 Q
I am asking for the names of any lawyers I
(~'T 24 who met with you in preparation for your deposition
'V 25 today.
j l
L
1 Davis 25
\\_/ -
2 MR. BENEDICT:
I am going to object and instruct you not to answer and'say that 3
4 that's,'at least as it has been de fined in this 5
case, protected information.
C:
6 MR. SELTZER:
I think you are incorrect 7
in your understanding.
There have been many 8
witnesses who have testified without objection g
to the people that they met with and the number 10 of days that they were prepared.
g 11 MR. BENEDICT:
Mr. Davis 12 MR. SELTZER:
It goes to the credibility k) 13 of this witness.
He is a non-party witness 14 and I can appreciate why you want t'o hide it.
15 The court will have to conlude what it 16 will from your concealment.
17 MR. BENEDICT:
If you would stop making
{
l 18 your silly personal ad hominem argum'ents, 19 you would have heard me say that I will let 20 Mr. Davis answer this question.
21 I consider it inappropriate.
I will 22 specify clearly that it doesn't constitute 23 anything of a waiver of an objection of any egT 24 future questions that you have of Mr. Davis'
' 'w,l 25 conta cts with counsel.
l
N 1
Davis 26
l 2
If you want to ask Mr. Davis what other 3
lawyers he met with with respec't to his testimony, 4
you are welcome to ask it.
({
5 Q
For how long did you meet with counsel 6
to prepare for this deposition?
7 MR. BENEDICT:
I am going to object, but 8
I am not going to instruct him not to answer.
9 You.may answer it.
10 A
I met a few hours Sunday evening and 11 several hours yesterday with counsel.
12 Q
Did they show you documents?
p
\\.
13 A
Yes.
14 Q
With whom if anyone from B&W did you 15 discuss the fact that you were going to be te s t'i fyin g ?
16 A
I discussed with no one at B&W the fact 17 that I was testifying.
18 Q
Who advised you that your testinony was
}
i 19 being sought?
20 A
Rod Benedict called me the first time that 21 I knew that my testimony was being sought.
22 Q
In what part of the B&W company were you 23 serving when you were a product manager?
24 A
I was still with the nuclear power 25 generation division at Old Forest Road.
1a
1 Davis 27
'd -
2 Q
That's a pretty big division.
3 Within what part of NPGD were you 4
working?
(.
5 A
I don't recall the exact title, but 6
something like product management.
7 Q
Who was the head of product management?
8 A
Dick Kosiba was the top level manager and 9
Bob Washer was an intermediate manager, and Bob Hamm 10 was my immediate manager.
11 Q
Did you have any professionals reporting 12 to you?
13 A
No, sir.
14 Q
You went from 15 people reporting to 15 you to no people reporting to you?
16 A
correct.
l 17 Q
What were your responsibilities as 18 product manager from April of '79 through'the date 19 when you left B&W 1ess than a year later? '
20 A
My responsibilities were basically l
21 to market, administer work for B&W's clients.
22 Details like preparing proposals, presentations and 23 negotiating contract terms in order to sell 24 enginee ring services to B&W clients.
25 Q
Were you selling engineering services l
1 Davis 28
/~S t
1
\\/'
2 rather than hardware?
3 A
That is right.
4 Q
Did someone succeed you as manager
( ~
5 of control and performance analysis?
6 A
Not immediately.
7 A
I don't recall who became unit manager 8
later, but I do recall that at some later date 9
Jim Carlton became the unit manager of that unit.
10 I can't recall the exact dates.
11 Q
After the Three Mile Island accident, 12 did anyone other than lawyers ask you any questions s
w_)
13 about your having received Bert Dunn's 14 February '78 memoranda?
15 MR. BENEDICT.
Could I hear that again?
16 Q
After the Three Mile Island accident, j
17 did anyone other than lawyers ever ask you any 18 questions about Bert Dunn 's February 1978 ' memoranda?
19 A
I don't believe anyone asked me did I l
20 receive Bert Dunn's memoranda. No one in the company i
i 21 that I recall asked me did I receive.that memoranda.
L
(_
22 Q
Did anyone talk to you about the subject 23 matter of those memoranda after the Three Mile Island
(~)
24 accident?
%)
25 A
I don't recall being asked to discuss the w
,,-e,
,-er-e
,m--,
--e
--e-
1 Davis 29
(~\\
~
U 2
subject of that memoranda after the date you called 3
o u t',
the March date.
4 Q
Is the occasion of this deposition the
(
5 first time that you can recall since the accident 6
having anybody ask you questions about Dunn's February 7
1978 memoranda?
8 A
That is correct.
9 Q
Prior to February 1978 were you aware of 10
-any instances in which a pilot operatedt relief valve 11 had failed to close on a B&W-supplied nuclear plant?
12 MR. BENEDICT:
The Davis-Be'sse February
\\_/
13
'78, Mr. Seltzer?
14 -
MR. SELTZER:
Yes.
15 A
I don't recall if I knew that prior to 16 February 1978.
l l
17 Q
Prior to February of 1978 were you aware 18 of any event in which there had been boiling in the 19 reactor coolant system of a B&W-supplied reactor?
20 A
I don't recall knowing that.
l l
21 Q
Before February 1978, did you have an
[
l 22 understanding that for most situations, the level of 23 wate r in the pressurize r went up when reactor coolant U)
[
24
. system pressure went ur S 25 A
I don't know if I knew that, Mr. Seltzer.
- ~
1 Davis 30
(~%
\\'
2 I really can't recall what I knew 3
prior to that date.
4 Q
Prior to that date, isn't one of the 5
things you were studying the st'atus of the reactor 6
coolant system under various operational transients?
7 A
Yes.
8 Q
Isn't it a fact that under the operational 9
transients that you can recall studying when reactor 10 coolant system pressure went up, pressurizer level 11 went up?
12 A
That may have been the case, but there are p(_/
13 an awful' lot of variables that you have to know before 14 you can make such a statement.
I am not sure I recall 15 such before February of
'78, anyway.
16 Q
Let me take the full period that you were 17 in control and performance analysis up to,the Three 18 Mile Island accident.
~
f 19 Is it correct that based on ths work that 20 you had done during that period, you knew that for 21 most situations when pressurize r level went up, 22 reactor coolant system pressure went up?
- 23 A
I am not sure that's the case.
Again, I
..(")
24 would have to have a lot more information before I can V
25 make that statement.
I'
-,-,--,-.r.
-..,.-,--,,---,,,r y
,,r ry v
-.-,.--.~g
,,--.-....m e--,
1 Davis 31 (D
\\ />
2 Again, I am not sure if before that date 3
I knew that.
4 Q
During the time that you were in the 5
control and performance analysis unit, were you aware 6
of any instance in which pressurizer water level would 7
rise while reactor coolant system pressure was falling?
8 A
I don't recall knowing that one way or the 9
other.
10 Q
You mean as you sit here today, you cannot 11 recall knowing any situation that would have caused 12 pressurizer level to rise while reactor coolant system
(
13 pressure fell?
14 MR. BENEDICT:
Asked and answered, but 15 go ahead.
t 16 Q
Is that right?
17 A
Please repeat the question.
18 A
Yes, that's my answer.
19 Q
Be fo re the Three Mile Island accident, 20 do you have any recollection of any instance in which 21 pressurizer water level rose at a B&W plant while 22 reactor coolant system pressure fell?
23 MR. BENEDICT:
Could I hear that again,
("N 24 Cathy, please?
\\_]
25 Q
Before Three Mile Island accident, is
1 Davis 32 s
N/-
2 there any instance that you can recall where 3
pressurizer level rose at a B&W plant while reactor 4
coolant system pressure fell?
(
5 MR. BENEDICT:
Are you asking for his 6
knowledge prior to the accident or whether 7
today he knows prior to the accident such a i
8 thing occurred?
9 I am unclear; I'm sorry.
10 MR. SELTZER:
I am asking whether he 11 recalls of such an instance before the Three 12 Mile Island accident.
gg
\\,,/
13 A
I don't recall knowing of such a thing.
14 Q
Was it your understanding before the 15 Three Mile Island accident that if pressurizer 16 level went down, reactor coolant system pressure was 17 also going down?
18 A
I don't recall if that was my understanding or not?
20 Q
one of the things which your unit did 21 was study the response of the reactor coolant system C
22 to varying pressures, is that right?
23 A
Yes.
I~T 24 Q
In studying the response of the reactor 25 coolant system to~ changes in pressure, did your unit i
-w
6 1
Davis 33
/~'T.
~
s-2 look at what happened to pressurizer water level?
3 A
Yes.
4 Q
Who in your unit during the '77 through 5
' 79 period do you recall being mos t knowledgeable g
6 about that work?
7 A
There was no one in my unit most knowledgeable 8
about this work.
There were many people in the unit 9
knowledgeable about this type of work.
10 Q
Were there any particular projects or 11 studies that were done that related to the ef fects of 12 change on pressure in pressurizer level?
O(_f 13 A
I don't recall any special projects.
14 Q
Was the effect of pressure changes on l
15 pressurizer level an element that often came up in l
l 16 broader studies that were being done on pressure 17 changes affecting the reactor coolant system?
18 A
Yes.
10 Q
Did you study operational transients 20 that involved the opening of the pilot operated relief l
21 valve?
(_
22 A
Yes.
l 23 Q
In any of those studies, did you postulate
('T 24 the failure to close the pilot operated relief valve?
(.)
25 A
Not that I recall, no.
I O
1 Davis 34
~
2 Q
Did any of.the studies of operational 3
transients include the opening of the code safety 4
valves on the top of the pressurizer?
5 A
I can't recall any specific transients 6
that we analyzed that lifted the code safeties.
7 Q
" Lifted" means open?
O A
Yes.
9 Q
" Challenged" would mean open also?
10 MR. BENEDICT:
Did you understand that 11 the word " challenged" meant that the code safety 12 was open?
N-)
13 THE WITNESS:
No, I was not familiar 14 with that term.
15 Q
Did you know before February 1978 what 16 a loss of coolant accident was?
17 A
Yes.
18 Q
Did you know that a loss of coolant accident 19 could result in core uncovery?
20 A
Yes.
21 Q
Did you know that a loss of coolant on accident could result in fuel damage?
~~
23 A
- Yes, f
24 Q
What kind of fuel damage did you 25 understand could result from a loss of coolant
1 Davis 35
. - ~
2 accident?
3 A
Clad failure.
4 Q
Did you understand that once the 5
cladding has failed, that can lead to a release of
{
6 radioactive fission products from the fuel rods into 7
8 A
Yes.
9 Q
Prior to February 1978 were there any 10 events other than a loss of coolant ac cA de nt or a 11 flow blockage accident which you knew could cause 12 core uncovery and fuel damage?
(~
(,
13 A
None that I can recall.
14 Q
Be fore February 1978 you knew'that a
15 loss of coolant accident was one of the most serious 16 accidents that could occur at a B&W nuclekr plant, 17 is that right?
18 A
I knew it was a serious accident.
~
19 Q
Did you know of any more serious 20 accidents that could occur at a B&W nuclear plant?
21 A
No.
I don't know of one that was more 22 serious.
23 Q
What is it about a loss of coolant U'"'
24
_ accident that to your mind made it the most serious 25 accident that you.could anticipate happening to a i
4
1 Davis 36 f'n 2
B&W nuclear plant?
3 A
The loss of coolant could rupture the 4
first boundary of the three boundary system; it could
(
5 rupture the fuel clad, and if you do that, initially 6
it could become worse later down the road.
So that's 7
why it was so important to not let that happen 8
initially.
9 Q
You said it was the first of three 10 b o un da rie s.
t 11 What are the other two boundaries?
12 A
The vessel and the containment building.
13 Q
You say it could lead to more dangerous 14 conditions down the road.
15 What were the more dangerous conditions 16 you were referring to?
(
17 A
It would be serious to ruptura the
~
18 fuel rods and have radioactivity in a reactor vessel.
19 It would be more serious if it goes out 20 to the reactor coolant system, secondary side, and 21 it would be even more serious if it got out of the l
22 containment.
1 23 I am saying it's the first step in going
~
24 down the road to more serious consequences.
(
25 Q
You are saying it would be more serious
-\\
=
1 Davis 37
~
2 if it got out of the1 containment.
3 Is the containment you are referring to 4
the reactor building?
(
5 A
Yes.
6 Q
If the radioactive fission products get 7
out of the reactor building,<then they are in the i
8 outside atmosphere. environment outside the 9
nuclear plant, right?
10 A
If they get outside the containment 11 building, yes, they are out in the atmosphere.
12 Q
Why did you say that would be a serious
("%
\\ms) 13 consequence?
14 A
Obviously you don't want the
- exposing 15' the environment to radioactivity above acceptable 16 limits.
17 Q
What was your understanding wh,ile you 18 were the head of the control and performance unit
~
l-l 19 about why obviously you wouldn't want such'd release i
~20 of radioactivity?
21 A
It's not good for the public health and
(-
l 22 safety to have doses above legally acceptable limits.
23 Q
What did you understand were the dangers
. [')\\
24 to public health and safety from exposure to
\\-
25 -
radioactivity above lawful limits?
1 Davis 38
- O) 2 MR. BENEDICT
Whatever you understood 3
during this time period.
4 A
I understood that the ultimate
(
5 consequence could be death if you have a lethal dose 6
of radioactivity.
7 Q
In other words, people could die,?
8 A
That is correct, they could die.
9 Q
You understood by February 1978 that if a 10 loss of coolant accident led to rupture'd fuel cladding 11 that meant that two of the three barriera to fission 12 product release had been breached, isn't that right?
(~/)
N-13 A
Repeat that again?
14 Q
A loss of coolant accident means that 15 the primary system has ruptured, isn't that right?
16 A
No.
17 Q
A loss of coolant accident -.where 18 do you think the coolant is coming from in a loss of 19 coolant accident?
20 A
Loss of coolant accident on the primary 21
- side, O.K.,
yes..
You are talking about a loss of 22 coolant accident in which the primary side is ruptured?
23 Q
Right.
(A 24
)
You understood that a loss of coolant 25 accident is a rupture in the bounaary of the primary
l 1
Davis 39
(\\-)-
2 coolant system, isn't that right?
3 A
Yes, that is correct.
4 Q
And my question is, if a loss of 5
coolant accident causes fuel cladding to fail, you g
6 understood by February 1978 that that meant two of 7
the three barriers to fission product release 8
had been breached, isn't that right?
9 A
Yes, I knew that before February 1978.
10 Q
That meant that there would. only be one 11 remaining barrier to the release of fission products 12 to the environment outside the nuclear plant, right?
g, 13 A
I believe that's correct, yes.
14 Q
There would only be one barrier to 15 prevent the serious consequences including possible 16 death, right?
17 MR. BENEDICT:
I object to the form of 18 the question.
~
19 You may answer if you understand it.
20 A
Yes-21 Q
Before February 1978, you understood, i
22 didn't you, that a loss of coolant accident coupled 23 with probable core uncovery and fuel damage was a
/~%
21 very serious matter, isn't that right?
k, 25 MR. BENEDICT:
Could I hear that back?
1 Davis 40
('N
~
(_)
2 A
Yes, I understand that was a very serious 3
matter.
4 Q
When did you first learn of the transient 5
at the Davis-Besse nuclear plant in which a pilot 6
operated relief valve failed to close?
7 A
I don't recall when I learned that.
8 Q
Are you aware today that there was such 9
an event?
10 A
Yes.
11 Q
Were you aware before the Three Mile 12 Island accident that there had been such an event?
r~T
()
13 A
Yes.
14 Q
Did you attend a meeting at which some 15 of the highlights of the Davis-Besse transient were 16 explained to a group of 25 or more B&W managers and i
17 executives?
l
~
18 A
I don't recall attending such a meeting.
j 19 Q
What was it in your mind that gave you l
20 the recollection that before the Three Mile Island 21 acpident you were aware of the Davis-Besse transient?
22 MR. BENEDICT:
Could I hear that again?
23 (Record read back.)
l g
24 MR. BENEDICT:
What does he recall about xY l
25 the transient?
l
1 Davis 41
.C V) -
2 Q
Do you understand?
3 A
I think so.
Why did I know that that 4
particular incident had happened?
({
5 Q
Yes.
6 A
I recall insulation being blown off of the 7
steam generator during that particular transient, and 8
it just stuck in my mind that that was a rather 9
peculiar thing to happen, and that piece of trivia 10 is one of the reasons at this point /,the only 11 reason I can give you for why I probably remembered 12 the Davis-Besse incident.
,~~
's-13 Q
Were you a regular recipien,t of site 14 problem reports when you were unit manage ?
15 A
I don't recall being a regular recipient.
t 16 Q
Were you an occasional recipient?
17 A
I was an occasional recipient of site 18 problem reports.
19 Q
Did you receive the site problem reports 20 for the Davis-Besse failed open PORV transient?
21' A
I don't recall.
22 Q
Let me show you GPU Exhibit 79 for 23 identification.
This is Bert Dunn's memo to Jim
()
24 Taylor, subject:
" Operator Interruption of High 25 Pressure Injection, February 16, 1978."
s
~~
1 Dav.is s
42 rN i
-fV)'
2 Do you see that you are mark d for a s
s s
s.
3 e py f this?
x
\\
., s 4
A Yes.
s s s 3
5 Q
Is this a, copy,of a memorandum that...
(
v t
.A.
,4 u
6 you received 'in:or-- about mid-February 19787
\\
~.
1 7
A I ti o'n ' t. recall receiving this memorandum.
s i
1 8
Q Was it..your practice in 1978 to read
,g w
9 internal correspoidence which was sent to you by 4
10 other B&W managers?
.(
JJ/,
~.
11 A
Yes.-
3 12 Q
Is there anything in GPU Exhibit 79 which 13 you would not have been able to understand in earlier 3
14 19787 3
x
\\;
15 MR. BENEDICT:
I object.
We have had s
16 this same' discussion wi'th Mr. Agar.' I find this N
17 gets into the whole area of i~nterpreting a 3
1 d'cument that,the witness 6cesn't re' call and --
18 o
,i
\\$
S hLTZE R,: Why don t you stop making a
('
MR.
19 s
- c -
3 '
20 sp,ee ch and, j ust make an objectien?
21
'MR.
BENEDICT:
All right.
I ob j e cit to the
/
l 22
- question, 3
s 23 Q^
Would you answer?
p 3.g MR. BENEDICT:
No.
I instruct the
~'q,)
25 witness not to answer.
4 h
-v.,
1 Davis 43
/().
2 Q
Are y u g ing to follow his instruction not to answer the question?
s A
Yes, sir.
4 Q
I w uld like to show you GPU Exhibit 78
(
5 which is Dunn's memo to Taylor dated February 9, 1978 6
and ask you whether you recall seeing a cqpy of that 7
8 memorandum be fore the Three Mile Island accident.
A No, sir, I don't recall receiving a copy g
f this document before the Three Mile Island accident.
10 t
MR. BENEDICT:
Mr. Seltzer just asked gg 12 if you had seen it prior to the Three Mile
('s t
)
Island accident.
13
-v Do you recall seeing it?
g A
I d n't recall seeing it.
15 16 Q
Do you recall seeing GPU 79, the memorandum that has your name on it,before the 17 18 Three Mile Isicnd accident?
A No, sir, I don't recall that..
gg 20 Q
After the Three Mile Island accident and before you got the telephone call from Rod Benedict, 21 22 did you see either of Dunn's two memos?
23 A
Yes, sir.
24 Q
Under what circumstances?
v 25 M R.
BENEDICT:
Answer the question.
1 Davis 44 O
\\-
2 A
In counsel's office.
3 Q
Which counsel?
4 MR. BENEDICT:
I think the record is 5
confused.
6 Why don't we go back to the question 7
when after the accident he first heard it.
8 Q
When after the accident and before Rod
~
9 called you on the telephone did you see either of 10 Dunn's two memos?
e 11 A
I am sorry.
12 No, I did not see either of these two
(")N
(_
13 memos.
14 Q
You can't recall seeing them?
15 A
I can't recall seeing them.
16 Q
When if ever is the first time you recall 17 knowing that B&W had proposed a subcooling rule for 18 the operation of high pressure injection?'
19 A
I don't recall,when I knew that.
20 Q
But there did come a point in time when i
21 you learned that B&W was proposing a subcooling rule 22 for high pressure injection?
23 A
I vaguely remember a subject like that.
{~J
\\
24 Q
Do you have any recollection in or about 25 February o f 1.9 7 8 asking anybody for a copy of Bert i
l l
..~..,
/
1 Davis 45 r%
~/
2 Dunn's February 9,
1978 memo?
3 A
No, sir.
4 Q
You knew in February of 1978 the 5
high pressure injection system was intended in a B&W
[
G plant to keep the core cooled during a small break 7
loss of coolant accident, isn't that right?
8 A
Yes.
9 Q
You understood in February of 1978 that 10 if during a small break loss of coolant accident there 11 were a premature termination of high pressure 12 injection, that would create a safety problem, 13 didn't you?
14 A
I don't recall whenI knew that.
I know 15 that now.
I am not sure when I knew that.
16 Q
You said you knew in February of 1978 that 17 high pressure injection was intended to keep the core
~
18 cooled during a small break LOCA, right?
19 A
Yes.
~
20 Q
If you don't have high pressure injection 21 during a small break LOCA, didn't you know that 22 that would create a safety problem?
23 A
Yes.
("N 24 Q
You knew that in February of
'78, right?
25 A
I believe I did.
a
1 Davis 46 r~
~)-
2 Q
Be fore. February 1978 do you recall ever
'3 getting a memorandum that forecast the possibility 4
of core uncovery fuel damage?
5 A
I don't recall getting such a memo.
(
6 Q
Do you have any recollection in or about 7
early 1978 of talking with Bert Dunn about the g
subject of operator interruption of high pressure 9
inj ection?
10 A
No, I don't.
11 Q
Do you have any recollection of talking 12 with B.uce Karrasch about operator interruption of
/~h
(,)
13 high pressure injection?
14 A
No.
15 Q
Don Roy?
h 16 A
No, sir.
17 Q
Joe Kelly?
18 A
No, sir.
i 19 Q
Do you have any recollection of 20 discussing with anyone in or around early 1978' 21 operator interruption of high pressure injection?
22 A
No, sir.
23 Q
At any of the meetings of the plant (V~}
24 design section, do you recall anybody raising the 25 subject of operator interruption of high pressure
1 Davis 47 p.
t' 2
injection?
i 3
A No, I don't recall that.
4 Q
In early 1978 did you understand that Dunn 5
was recommending that B&W should send new procedures CJ 6
to its customers in order to prevent premature 7
termination of high pressure injection?
8 MR. BENEDICT:
May I hear that again?
9 A
I don't know when I knew that.
10 Q
Did you learn that some time before the 11 Three Mile Island accident?
IL' A
I don't recall.
/^)
(_/
13 Q
Do you have any reason to believe that 14 B&W sent any warnings to any customers regarding 15 premature termination of high pressure injection e
16 prior to the Three Mile Island accident?
17 A
I really don't know.
~
18 Q
You are not aware of any such warning 19 being sent, are you?
20 A
I am not aware of any such warning.
1 b
21 I don't know.
I 22 Q
After mid-February 1978, did you do l
i 23 anything to determine whether anyone in B&W was
(~N 24 taking any action with respect to advising customers
\\_.
25 about the danger of premature termination of high
1 Davis 48
(
2 pressure injection?
'~~U 3
A Was the question did I do anything?
4 Q
Yes.
{
5 A
Not that I can recall.
6 Q
After mid-February 1978, did you do 7
anything to determine whether B&W was advising 8
customers of new guidelines for the operation of high I
9 pressure injection?
~
10 MR. BENEDICT:
Cathy, could:I hear that 11 back?
12 (Record read back.)
b)
V 13 A
I don't recall doing anything like that.
14 Q
When is the first time that you can recall 15 being aware that your name appears as a copyee of 16 GPU 797 17 A
When counsel informed me.
18 Q
That's 19 MR. BENEDICT:
I think he means me.
20 A
When my counsel informed me that my name 21 was on this document.
22 Q
When was that?
23 A
That was 24 MR. BENEDICT:
To the best of your 25 recollection.
4 i
i 1
Davis 49
('N t
I 2
A about March of this year I was aware 3
my name was on that document.
4 Q
Did you understand in February 1978
(
5 that it was important to ensure that the re ac tor 6
coolant system was subcooled before high pressure 7
injection was terminated?
8 A
I don't know if I knew that or not at that 9
time.
10 Q
Did you know that before th.e Three Mile
~
11 Island accident?
12 A
I don't know if I knew that.
(T..
d
(_)
13 Q
Before the Three Mile Island accident, 14 did you understand that it was necessary to keep 15 the reactor coolant system subcooled under transient 16 conditions?
17 A
Yes.
18 Q
But you don't recall knowing whether it
~
19 was important that the reactor coolant system be 20 subcooled before the high pressure injection system 21 was terminatsd?
' (~
22 MR. BENEDICT:
Asked and answered.
23 You may answer.
24 A
Right.
I am not that -- I don't know.
25 Q
Where.were you on the day of the Three
I
~
1 Davis 50 p
(.-
2 Mile Island. accident?
A I was at work.
~
4 Q
Did you do anything different that day 5
fr m y ur normal work procedures?
[{
6 A
Not that I recall.
7 Q
When in April '79 did you switch from 8
being manager of control and performance to being
-g product manager?
f 10 A
It was approximately seven weeks after t
the Three Mile Island accident that I made the 1g 12 transition to product manager.
((h/
13 Q
So since the Three Mile Isl'and accident i
g4 took place on March 28, 1979, you made.thA transition some time in May, right?
i 15 16 A
To the best of my recollection, it was 17 probably some time in May.
18 Q
So GPU 506 is'in that respect'not 19 scrupulously accurate, is that right?
~
A It may have been probably May, now 20 that I think about the fact that it was approximately 21 22 seven weeks after the incident -- probably May, 23 maybe a more correct date.
(-}
24 MR. SELTZER:
Do you want to write in
'LJ 25 May on the exhibit?
1 Davis 51
- \\-
2 Q
After the accident, did your group have 3
any responsibility for the evaluation of the 4
e f fe ct of surge line configuration on the draining
(
5 of the pressurizer?
6 MR. BENEDICT:
Could I hear that back?
7 (Record read back.)
8 A
Yes, sir.
9 Q
What was your group's responsibility?
10 A
We analyzed the B&W configuration and 11 several of the competitors' configurations to 12 determine the dif fe rence s and what effect it might
('~h
(,)
13 have.
14 MR. SELTZER:
I would like to mark as 15 GPU 507 a memorandum from D.
W.
Fairbrother 16 to distribution, April 12, 1979, subject:
17
" Summary of Pressurizer Level Investigation /
18 Instruction," with a copy marked for' Ron 19 Davis.
20 (Me mo randum from D.
W.
Fairbrother 21 to distribution, April 12, 1979, subject:
4 22
" Summary of Pressurizer Level Investigation /
23 Instruction," with a copy to Ron Davis, marked
(-}
24 GPU Exhibit No. 507 for identification as of
'\\_/
25 this date.)
1 Davis 52 l
'(O
(,)
2 Q
In connection with this document, I w uld like you to look at the introduction on 3
4 the first page and then the paragraph on page 3 entitled " Surge Line configuration."
{
5
'6 First, is GPU 507 a copy of a memorandum 7
that you received shortly after the Three Mile g
Island accident?
9 A
I don't recall receiving this.
10 Q'
Do you see the paragraph en itled 11
" Surge Line Configuration" on page 37 12 A
Yes, sir.
)
13 Q
Does.that describe the are a' o f s
)
14 investigation that you said that your unit had done 15 after the accident?
16 MR. BENEDICT:
I will object to form, 17 but you may answer.
18 A
I recall our unit did some investigation 19 in this area, particularly calculating surge line 20 Delta Ps to put into a dynamic type model to assess 21 the surge line configuration.
22 Q
I am going to tell you now the questions 23 I want to ask on this.
If Rod Benedict wants to 24 confer with you before you give answers, that's fine, O,
25 I want to avoid recalling you as a witness on another
1 Davis 53 (h
\\s /
2' day, and we agreed that if the questions strayed 3
beyond Dunn's memos or your curriculum vitae, there
~
~
4 would be an opportunity to confer with counsel before 5
you answer.
C.
6 I want to verify that the statements and 7
conclusions that are in this paragraph are consister~.
8 with your recollection of the findings of your group 9
when it was studying surge line configuration.
10 -
MR. BENEDICT:
I haven't re,ad the 11 paragraph, and let's go off the record to give 12 me time to do that.
O)
(
13 (Discussion of f the re co rd. ')
14 BY MR. SELTZER:
15 Q
You indicated before we took a short i
16 recess that the information that's contained in the 17 middle paragraph on page 3 refers to an area of work 18 that your unit was doing after the Three Mile Island
(
19 accident.
20 I believe you also said that one of the l
l 21 things which your unit did was compare the surge line 22 configuration of the B&W design with the surge line 23 configuration of the competitors' design.
24 A
That is correct.
s i
25 Q
The competito rs you were comparing with l
1 Davis 54 (lh N-2 were pressurizer vendors?
3 A
some were.
4 Q
Did you compare B&W's with the design
- {
5 of Westinghouse and Cumbustion Engineering?
6 A
Yes.
7 Q
Were there other plants which included 8
pressurizers?
9 A
I don't recall.
10 Q
All the ones that you can recall comparing 11 were PWR suppliers, right?
12 A
Yes.
A(,,)
13 Q
And the only ones that you can recall 14 comparing, as you sit here today, was Westinghouse 15 and Combustion Engineering, is that right?
e 16 A
That is right.
17 Q
Do you recall from your B&W employment 18 that there is a loop seal in the surge lin'e connected I
i 19' to the pressurizer of a B&W 177 plant?
l l
20 A
Yes, I recall that.
l 21 Q
Do you also recall that the surge line C
22 connected to the pressurizers in the Westinghouse 23 and Combustion Enginee ring plant does not have a
/"
24 loop seal?
N-]T i
25 A
I recall that.
i
1 Davis 55 O(_/-
2 Q
The surge line is the'line that connects 3
the pressurizer to the rest of the reactor coolant 4
system, is that correct?
5 A
That is correct.
{
6 Q
In other words, it's the line through which 7
water can pass from the pressurizer to the rest 8
of the reactor coolant system?
9 A
That is right.
10 Q
Do you recall that because,there is a 11 loop seal in the B&W design water could not drain out 12 of the pressurizer at any point during the Three Mile p
(,)
13 Island transient?
14 A
I don't know that for a fact."
15 Q
From the studying or modeling that was 16 done after the Three Mile Island accident, did your 17 unit deduce that the loop seal would tend to keep the 18 water in the pressurizer rather than letti'ng it 19 evacuate into the rest of the reactor coolant' system?
20 A
My unit did not deduce that, that I recall.
21 Q
Are you aware of any unit working on that?
22 A
The circumstances were that in my unit 1
23 we calculated the Delta P of the various surge lines.
(~
24 We gave them to another unit I don't recall which
(_h
)
25 unit, because there we re a couple of units doing
1 Davis 56 7'N 2
these types of analysis for them to take that 3
information and assess what was -- what would be 4
the result, depending on the configuration of surge 5
line.
(
6 We-calculated that initial condition, 7
I keep referring to, the K factor, the Delta P 8
involved.
We didn't assess in my unit whether that 9
was the performance of the surge line.
10 Q
I understand now.
4 g
11 Did you come to know after the Three 12 Mile Island accident that a surge line configuration O)
(_
13 that has a continuous downward slope from-the 14 pressurizer to the hot leg would have all' owed the 15 pressurizer to drain after the water level in the 16 hot leg dropped below the surge line connection point?
17 A
I don't recall the results of this 18 particular study.
19 Q
I am not asking the results of this
- 20 Particular study.
21 Did you come to know from this study L
22 or any other study or any other word of mouth or 23 anything, did you come to know that if the surge line
(~
24 had not had a loop seal but just had a continuous
(-)T l
25 downward slope, that it would have permitted the 1
-...y-
1 Davis 57 bb/
2 pressurizer water.to drain into the rest of the 4
4 A
I am not sure I knew that.
5 Basic engineering principles would lead 6
you in that direction, but not knowing all the 7
variables and circumstances, I couldn't say absolutely 8
that would be the case.
9 Q
Are you aware of any reason why the B&W 9
10 design included a loop seal in the pressurizer 11 surge line where competitors did not have a loop seal?
12 A
No, sir, I do not know.
13 Q
Is there anything yo'u would' like to tell 14 me that I haven't asked you about?
15 A
No.
16 MR. BENEDICT:
I object.
That's an i
i 17 improper question.
L 18 But you got an answer anyway. ~
l 19 Q
Have you ever given testimony before in l
20 connection with the Three Mile Island accident?
21 A
No.
22 Q
Did anybody discuss with you at any time i
23 prior to the Three Mile Island accident whether
{~}
24 operating the B&W plant so it became entirely
- N._/
25 water solid in the primary system would create any
1 Davis 58 M
2 operational difficulties?
3 A
I don't recall talking to'anyone about 4
that.
5 Q
Did you ever hear anybody raise an issue
[
6 whether going solid could create any damage to vessel 7
internals or pipes or valves?
8 A
I don't recall talking to anybody about g
that subject.
10
-Q Did you ever hear that subj ct raised 11 before the Three Mile Island accident?
I 12 A
I don't recall a specific instance when
(~))
(,
13 that subject was raised, although it's Iairly 14 common knowledge that that could be a serious problem.
t L
15 Q
What do you mean it's fairly common 16 knowledge that that could be a serious pr$blem?
i 17 How do you know that?
Were there l
a i
18 seminars on that at B&W?
~
t 19 A
No.
20 Q
Were there general discussions in the 21 plant design section meetings about that being a 22 general problem?
23 A
I don't recall.
24 Q
In fact, you don't recall ever hearing
,A 25 it discussed by anyone, do you?
1 Davis 59 2
A That is ri gh t.
3 g
You don't recall ever seeing a written 4
execution of any problems associated with going
['
5 solid, do you?
-6 A
That is right.
7 Q
You don't have.any basis that you can 8
testify to for saying that there was a general 9
concern over damage to vessel and going solid, do you?
10 MR. BENEDICT:
I object to the question.
11 A
I don't understand the question.
12 Q
Did your unit ever do any work to analyza f%
(_)
13 the effects of going solid on any part of the 14 reactor coolant system?.
15 A
I don't recall any.
16 MR. SELTZER:
I don't have any further 17 questions.
i 18 MR. BENEDICT:
I don't either.
19 (Time noted:
11:50 p.m.)
~
l l
20 RONALD DAVIS 21 km
(
22 Subscribed and sworn to 23 before me this day i
O 24 of 1982.
)
25 1
(
[
1 60 2
CERTIFICATE 3
STATE OF NEW YORK
)
4
)
SS.
(O COUNTY OF NEW YORK
)
5 I,
CATHERINE Cook a Notary 6
i Public within and for the State of New York, do hereby 7
certify that the foregoing deposition of 8
RONALD DAVIS was taken before me April 27, 1982 on 10 L
That the said witness was duly sworn before 11 the commencement of his testimony and that the 12 within transcript is a true record of said testimony; 13 That I am not connected by blood or marriage 14 with any of the parties herein nor interested directly l
15 or indirectly in the matter in controversy, nor am I l
in the employ of any of the counsel.
17 IN WITNESS WHEREOF, I have hereunto set 18 my hand this 7+k day of b,,, !
l 1982.
i 19
/
20 (L
21 A
iMr 44 ('
cAmesaIsm coom 1
22 1
23 24 25
61 INDEX NESS PAGE tid Dcvis 3
- x-EXHIB ITS FOR IDENT.
Resume of' Ronald Davis Memorandum from D.
W. Fairbrother to distribution, April 12, 1979, 51 i
subject:
" Summary of Pressurizer Le vel In ve s tigation/ Ins truction with a copy to Ron Davis
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